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Accessibility

Dernière mise à jour : 2022-01-17

Introduction and Purpose

The Ontario government has passed legislation known as the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

The AODA requires organizations in the public and private sectors of the Province of Ontario to meet certain accessibility standards with respect to the products, services, employment opportunities and facilities that they offer to members of the public.

The AODA objectives are :

  • To enable persons with disabilities to benefit from these products, services, employment opportunities and facilities in the same way as other members of the public and
  • To involve persons with disabilities in the development of accessibility standards.

To date, the Ontario government has passed Regulation 191/11 : Integrated Accessibility Standards (the Regulation), which sets out the accessibility standards to be adopted under the AODA

The customer service requirements of the standards, set out in the Regulation, have been implemented by means of our Accessible Customer Service Policy.

The other requirements set out in the Regulation, which apply to the Company, have been implemented by means of our Accessibility Standards Policy and our Accessibility Plan.

For the purposes hereof, the terms "the Company", "we", "our", or "us" refer to Beneva1.

Our Commitment

The Company is committed to treating all people in a way that allows them to maintain their dignity and independence. We are committed to meeting the needs of persons with disabilities in a timely manner in accordance with the provisions of the Company’s policies and the AODA.

Feedback Process

Our ultimate goal is to meet and exceed customer expectations when serving customers with disabilities.

Comments on our success in achieving this goal are appreciated and can be made by completing and returning the Feedback form to the Accessibility Committee, or by contacting us :

Email : [email protected]

All feedback and complaints will be directed to our Accessibility Committee. We will acknowledge receipt of all feedback and complaints in writing. Our response time will depend on the nature of the feedback or complaint. However, we endeavour to respond to all feedback and complaints in a timely manner. If the response is not satisfactory, customers may request in writing that the matter be escalated to management for a final decision.

1 “Beneva“ means La Capitale Civil Service Insurer Inc. and La Capitale General Insurance Inc, as insurers, and Beneva inc., damage insurance agency and financial services firm, as well as their partners and duly authorized representatives.

Accessible Customer Service Policy

This Accessible Customer Service Policy ("the Policy") establishes accessibility standards for the Company’s provision of insurance and financial products and services to persons with disabilities.

Regulation 191/11 : Integrated Accessibility Standards (the Regulation), which sets out the accessibility standards to be adopted under the AODA and applies to all employees, volunteers, agents or contractors who deal with members of the public or other parties in Ontario on behalf of the Company.

Throughout the Policy, the terms "the Company," "we," "our" or "us" refer to Beneva1.

For definitions of terms used in this Policy, please refer to Section 8.

1. Our commitment

We are committed to providing our products and services to the public in a way that respects the dignity and independence of persons with disabilities.

We are committed to giving persons with disabilities the same opportunity to access and benefit from our products and services in the same place and in a similar way as other customers.

We will use reasonable efforts to ensure that our policies, practices and procedures are consistent with the following principles :

  • We will integrate the way in which we provide insurance and financial products and services to persons with disabilities with the way in which we provide products and services to other customers, unless an alternate measure is necessary, whether temporarily or on a permanent basis, to enable a person with a disability to obtain, use or benefit from a particular product or service.
  • We will give persons with disabilities an opportunity equal to that given to other members of the public to obtain, use or benefit from our products and services.

2. Providing products and services to persons with disabilities

We demonstrate our commitment to serving persons with disabilities in the following ways :

2.1 Communication

We will communicate with persons with disabilities in a manner that takes their disabilities into account.

We will train staff members who communicate with customers or other parties on our behalf how to interact and communicate with persons with various types of disabilities.

2.2 Telephone services

We will train staff members to communicate with persons with disabilities over the telephone in clear and plain language and to speak clearly and slowly.

We will offer to communicate with persons with disabilities using assistive telephone services ( where available ) or by email.

2.3 Assistive devices

We will permit persons with disabilities to use their own assistive devices to obtain, use or benefit from our products and services, unless the use of such devices could reasonably present a health, safety or security risk to such persons, the Company or others. In these cases, we may make other reasonable arrangements to facilitate the ability of persons with disabilities to obtain, use or benefit from our products and services.

Assistive devices may include ( but are not limited to ) communication aids, cognition aids and mobility aids.

Persons who use their own assistive device on the Company’s premises must remain in control of the devices at all times.

2.4 Billing

We will provide accessible invoices to all of our customers. Invoices will be provided in hard copy, large print or email format, upon request.

We will answer any questions customers may have about the content of their invoices in person, by telephone or email.

3. Use of service animals and support persons

We will ensure that any persons with a disability who are accompanied by a guide dog or service animal may keep the animal with them on those parts of our premises that are open to the public and other third parties, unless the animal is otherwise excluded by law from our premises.

If a service animal is excluded by law from our premises, we will take reasonable measures to enable a person with a disability to obtain, use or benefit from our products and services. Persons who are accompanied by a guide dog or service animal must maintain control of the animal at all times.

Any persons with a disability who are accompanied by a support person will be allowed to enter our premises with their support person. At no time will persons with a disability who are accompanied by a support person be prevented from having access to their support person while on our premises.

We may require a person with a disability to be accompanied by a support person when on our premises, but only if a support person is necessary to protect the health and safety of the person with a disability or the health or safety of others on the premises.

In appropriate circumstances, we may require persons with a disability to provide their consent before we disclose confidential information to them in the presence of a support person.

4. Notice of temporary disruption

We will provide the public with notice in the event of a temporary disruption in our facilities or services usually used by persons with disabilities. The notice will include information about the reason for the disruption, its anticipated duration and a description of any available alternative facilities or services.

The notice will be posted at all public entrances and service counters on our premises, or it will be given by such other method that we consider reasonable in the circumstances.

5. Training

We will train :

a) All employees, agents, volunteers and others who deal with the public or other parties on our behalf

and

b) All persons who participate in the development of our customer service policies, practices and procedures on the practices and procedures that we follow in providing our products and services to persons with disabilities

We will train each person as soon as is practicable after they are assigned their duties. Training will include the following :

  • A review of the purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the Regulation 191/11 : Integrated Accessibility Standards.
  • How to interact and communicate with people with various types of disabilities.
  • How to interact with persons with disabilities who use an assistive device or require the assistance of a guide dog or other service animal or the assistance of a support person.
  • How to use equipment or devices provided by the Company that may help with the provision of products or services to a person with a disability.
  • What to do if a person with a particular type of disability is having difficulty accessing our products or services

Training will be provided on an ongoing basis to reflect changes made to our policies, practices and procedures governing the provision of products and services to persons with disabilities.

6. Feedback process

Our ultimate goal is to meet and exceed customer expectations when serving customers with disabilities.

Comments on our success in achieving this goal are appreciated and can be made by contacting us using the information in the Contact Us section of this Policy.

Alternatively, customers may complete the feedback form found on the Beneva.ca website.

All feedback and complaints will be directed to our Accessibility Committee. We will acknowledge receipt of all feedback and complaints in writing. Our response time will depend on the nature of the feedback or complaint. However, we endeavour to respond to all feedback and complaints in a timely manner. If the response is not satisfactory, customers may request in writing that the matter be escalated to Management for a final decision.

7. Changes to the Policy

We are committed to developing customer service policies that respect and promote the dignity and independence of persons with disabilities. Therefore, no changes will be made to this Policy before considering the impact on persons with disabilities.

8. Definitions

For the purposes of this Policy, the following terms have the meanings indicated.

"Disability"

means :

(a) Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device

(b) A condition of mental impairment or a developmental disability

(c) A learning disability or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language

(d) A mental disorder or

(e) An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997 (Ontario).

"Guide dog" means a guide dog as defined in Section 1 of the Blind Persons’ Rights Act (Ontario).

"Service animal," for persons with a disability, means an animal :

(a) If it is readily apparent that the animal is used by the persons for reasons relating to their disability or

(b) If the persons provide a letter from a physician or nurse confirming that they require the animal for reasons relating to the disability.

"Support person," in relation to persons with a disability, means another person who accompanies them in order to help with communication, mobility, personal care or medical needs or with access to goods or services.

Contact Us

To provide us with your feedback or to find out more about our Accessible Customer Service Policy, you are invited to contact us :

Accessibility Committee
Email : [email protected]

1”Beneva” means La Capitale Civil Service Insurer Inc. and La Capitale General Insurance Inc, as insurers, and Beneva inc., damage insurance agency and financial services firm, as well as their partners and duly authorized representatives.

Accessibility Standards Policy

This Accessibility Standards Policy ("the Policy") is intended to meet the requirements of the Integrated Accessibility Standards Regulation ("the Regulation") and should be read together with the Accessibility Plan for the Company’s complete response to the Regulation’s requirements.

This Policy establishes accessibility standards applicable to persons with disabilities in the following areas of the Company’s operations : information and communications, employment and human resources, and facilities open to members of the public.

The Company is governed by this Policy, the Company’s Accessible Customer Service Policy and such other policies that the Company may adopt to make its products, services and operations accessible to persons with disabilities.

This Policy applies to all employees, volunteers, agents or contractors who deal with members of the public or other third parties in Ontario on behalf of the Company.

The standards set out in the Regulation, as reflected in this Policy, are not a replacement or a substitution for the requirements established under the Ontario Human Rights Code; nor do the standards limit the obligations owed to persons with disabilities in Ontario under any other legislation.

This Policy will be implemented in accordance with the time frames established by the Regulation. Throughout the Policy, the terms "the Company", "we", "our" or "us" refer to Beneva1.

For the meaning of terms used in this Policy and not otherwise defined, please refer to the "Definitions" section.

Our Commitment

The Company is committed to treating all people in a way that allows them to maintain their dignity and independence. We are committed to meeting the needs of persons with disabilities in a timely manner in accordance with the provisions of this Policy, the Company’s Accessibility Plan and the Regulation.

The Company demonstrates its commitment to serving persons with disabilities in the following ways :

A. Accessibility Policies, Self-Service Kiosks and Training

1. Accessibility Policy

We will establish, maintain and document policies that explain how the Company will meet its obligations to persons with disabilities under the Regulation. We will make such policies publicly available and, upon request, provide them in an accessible format.

2. Accessibility Plan

We will establish, maintain and document a Multi-Year Accessibility Plan ("the Accessibility Plan"), which will outline our strategy to prevent and remove barriers for persons with disabilities within our operations and to improve opportunities for persons with disabilities.

We will post the Accessibility Plan on our website and, upon request, will provide a copy of it to members of the public in an accessible format. We will review and update the Accessibility Plan at least once every five years.

3. Self-Service Kiosks

If we use self-service kiosks to provide insurance or other financial products or services to customers, we will consider the accessibility of the kiosks to persons with disabilities.

"Kiosk" means an interactive electronic device that allows members of the public to access the Company’s products and services.

4. Training

As soon as is practicable, we will provide training on this Policy, the Regulation and the Ontario Human Rights Code (as it pertains to persons with disabilities) to :

  • All of the Company’s employees and volunteers
  • All persons who participate in the development of the Company’s policies
  • All other persons who provide products or services in Ontario on behalf of the Company.

We will keep records of the training we provide, including the dates on which training is provided and the number of participants.

The training will be appropriate to the duties of the employees, volunteers and other persons. The training will be conducted on an ongoing basis to reflect any changes to this Policy and to such other policies that the Company may from time to time adopt in order to make its products, services and operations accessible to persons with disabilities.

B. Information and Communications Standards

1. Feedback

Our process for receiving and responding to customer feedback will be accessible to persons with disabilities. We will arrange to provide accessible formats and communication supports, upon request, to enable persons with disabilities to provide feedback on the Company’s products and services, including the manner in which these products and services are delivered.

"Accessible formats" may include large print, electronic and other formats usable by persons with disabilities.

"Communication supports" may include devices to assist persons with disabilities who are hearing-impaired, communication using plain language and other supports that facilitate communications between the Company and its customers.

2. Accessible Formats and Communication Supports

To assist persons with disabilities in their communications with the Company, we will, upon request: 

  • Arrange to provide accessible formats and communication supports for persons with disabilities
  • Consult with the person making the request to determine the suitability of a particular format or communication support and
  • Inform members of the public of the availability of accessible formats and communication supports.

We will provide accessible formats and communication supports :

  • In a timely manner that takes into account accessibility needs due to a person’s disability and
  • At a cost that is no more than the regular cost charged to the Company’s other customers

3. Accessible Websites and Web Content

Except where it is not practicable, we will ensure that :

  • New websites, including non-exempt content posted on the websites, comply with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level A, by the dates indicated in the Regulation and
  • All of the Company’s websites and web content comply with the WCAG 2.0, Level AA (other than success criteria 1.2.4 Captions (Live) and success criteria 1.2.5 Audio Descriptions (Pre-recorded), by the dates indicated in the Regulation

"WCAG 2.0" is an internationally accepted standard for web accessibility developed by an international team of experts.

C. Employment Standards

1. Recruitment – General

We will inform our employees and members of the public of the availability of accommodation for applicants with disabilities who are participating in the Company’s recruitment process.

2. Recruitment, Assessment or Selection Process

We will notify applicants for employment who are individually selected to participate in an assessment or selection process that they may, upon request, have access to accommodations with respect to the materials or processes to be used. We will consult with selected applicants who request an accommodation and will arrange to provide a suitable accommodation in a manner that takes their accessibility needs due to disability into account.

3. Notice to Successful Applicants

When making offers of employment, we will inform all successful applicants of this Policy and such other policies that the Company may, from time to time, adopt in order to accommodate employees with disabilities.

4. Informing Employees of Supports

We will inform our employees about this Policy, and such other policies that the Company may, from time to time, adopt in order to support employees with disabilities. This information will include policies on the provision of job accommodations that take into account the accessibility needs of employees due to disability. This information will be provided to new employees as soon as is practicable following the commencement of employment. Training will be provided on an ongoing basis to reflect changes made to the Company’s policies.

5. Accessible Formats and Communication Supports for Employees

Upon the request of an employee with a disability, we will consult with the employee to arrange for the provision of accessible formats and communication supports for :

a) Information needed to perform the job duties and

b) Information generally available to other employees.

In determining the suitability of an accessible format or communication support, we will consult with the employee making the request.

6. Workplace Emergency Response Information

We will provide individualized workplace emergency response information to employees who have a disability if the disability is such that the individualized information is necessary and we are aware of the need for accommodation due to the disability.

If an employee requires assistance, we will, with the employee’s consent, provide the workplace emergency response information to the person designated by the Company to provide assistance to the employee.

We will provide individualized workplace emergency response information as soon as is practicable, once we become aware of the need for accommodation due to the employee’s disability.

We will review the individualized workplace emergency response information when :

a) The employee moves to a different location within the Company

b) The employee’s overall accommodations needs or plans are reviewed and

c) The Company reviews its general emergency response policies.

7. Documented Individual Accommodation Plans

We will adopt a written process for the development of documented individual accommodation plans for employees with disabilities that meets the requirements of the Regulation.

8. Return-to-Work Process

In accordance with the Regulation, we will develop and maintain a documented return-to-work process for our employees who have been absent from work due to a disability and who require disability related accommodations in order to return to work. The return-to-work process will outline the steps that the Company will take to facilitate the return to work and will include documented individual accommodation plans as part of the process.

9. Performance Management, Career Development and Advancement, and Redeployment

We will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when conducting our performance management process, when providing career development and advancement to our employees and when redeploying employees.

"Performance management" means a process for assessing and improving employee performance, productivity and effectiveness.

"Career development and advancement" includes the assignment of an employee from one position to another within an organization involving an increase in pay or greater responsibility or elevation to a higher level within the organization (or a combination of the above).

"Redeployment" means the reassignment of an employee to another department or position within the organization when a particular department or position no longer exists.

D. Design of Public Spaces

When constructing new spaces on our premises for use by the public, or when redeveloping existing ones, we will meet the design and accessibility requirements set out in the Regulation. Examples of public spaces include outdoor walkways, parking facilities, service counters and waiting areas.

Definitions

For the purposes of this Policy, the following terms have the meanings indicated.

"Disability" means :

a) Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device

b) A condition of mental impairment or a developmental disability

c) A learning disability or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;

d) A mental disorder or

e) An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997 (Ontario).

Contact us

To find out more about our Accessibility Standards Policy our Accessibility Plan, please feel free to contact us :

Email : [email protected]

1“Beneva“ means La Capitale Civil Service Insurer Inc. and La Capitale General Insurance Inc, as insurers, and Beneva inc., damage insurance agency and financial services firm, as well as their partners and duly authorized representatives.

Accessibility Plan

Requirements

A. Accessibility Policies, Self-Service Kiosks and Training

1. Accessibility Policy

Goal
  • Establish, maintain and document policies that explain how the Company will meet its obligations to persons with disabilities under the Integrated Accessibility Standards Regulation (“the Regulation”) and
  • Make such policies publicly available and provide them in an accessible format, upon request.

AODA compliance date : January 1, 2014

Our Actions

We have developed, documented and updated an Accessibility Standards Policy, an Accessible Customer Service Policy and a Multi-Year Accessibility Plan. These documents are available on our corporate website. Members of the public may receive a copy in an accessible format, upon request. The Multi-Year Accessibility Plan describes the measures that the Company has taken to eliminate accessibility barriers for our clients and employees in accordance with the schedule set out in the Regulation. This plan will be reviewed and updated at least once every five years to ensure compliance

2. Self-Service Kiosks

Goal
  • Take into account accessibility for persons with disabilities to self-service kiosks to provide products or services to customers.
  • “Kiosk” means an interactive electronic device that allows members of the public to access the Company’s products and services.

AODA compliance date : January 1, 2014

Our Actions

The Company does not currently use self-service kiosks to provide insurance or other financial products or services to its customers. If we decide to use self-service kiosks in the future, we will consider the accessibility of the kiosks to persons with disabilities.

3. Training

Goal
  • Provide training on the Regulation and the Ontario Human Rights Code (as it pertains to persons with disabilities) as soon as is practicable to :
    – All of the Company’s employees and volunteers
    – All persons who participate in the development of the Company policies and
    – All other persons who provide products or services on behalf of the Company.
  • Keep records of the training we provide, including the dates on which training is provided and the number of participants and
  • Provide training on an ongoing basis to reflect any changes to the Policy and to such other policies that the Company may from time to time adopt in order to make its products, services and operations accessible to persons with disabilities.

AODA compliance date : January 1, 2015

Our Actions

The Human Resources Department has developed training courses, which are available on our intranet. We ensure that our employees, volunteers and all other persons who provide products and services on the Company’s behalf all take these training courses concerning, in particular :

  • Our Accessibility Standards Policy
  • Our Accessible Customer Service Policy
  • The requirements of the accessibility standards referred to in the Regulation, and
  • The provisions of the Human Rights Code as it pertains to persons with disabilities.

We document the names of those who have received the training and the dates.

B. Information and Communications Standards

1. Feedback

Goal
  • Ensure that our process for receiving and responding to customer feedback is accessible to persons with disabilities by arranging, upon request, to provide accessible formats and communication supports to assist them.
  • “Accessible formats” may include large print, electronic and other formats usable by persons with disabilities.
  • “Communication supports” may include devices to assist persons with disabilities who are hearing-impaired, communication using plain language and other supports that facilitate communications between the Company and its customers

AODA compliance date: January 1, 2015

Our Actions

We have developed a process that enables persons with disabilities to provide feedback on the Company’s products and services, including the manner in which these products and services are delivered. We will provide accessible formats and communication supports, upon request. The feedback may be provided in person, by phone or email or through the Company’s website. We will acknowledge receipt of all feedback in writing. We have, moreover, set up an Accessibility Committee, which will ensure that a response is provided as quickly as possible.

2. Accessible Formats and Communication Supports

Goal
  • To assist persons with disabilities in their communications with the Company, we will :
    – Arrange, upon request, to provide accessible formats and communication supports for persons with disabilities, doing so in a timely manner that takes into account accessibility needs due to a person's disability and
    – At a cost that is no more than the regular cost charged to the Company’s other customers.
  • “Accessible formats” may include large print, electronic and other formats usable by persons with disabilities.
  • “Communication supports” may include devices to assist persons with disabilities who are hearing-impaired, communication using plain language and other supports that facilitate communications between the Company and its customers

AODA compliance date: January 1, 2015

Our Actions

We will, upon request, provide accessible formats and communication supports, doing so in a timely manner that takes into account accessibility needs due to a person's disability. The cost for our doing so will be no more than the regular cost charged to the Company’s other customers. Further information on the availability of accessible formats and communication supports is provided in our Accessible Customer Service Policy.

3. Accessible Websites and Web Content

Goal
  • Except where it is not practicable, we will :
    – Make new websites, including non-exempt content posted on the websites, comply with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, Level A, by the dates indicated in the Regulation.
    – Make all of the Company’s websites and web content comply with the WCAG 2.0, Level AA (other than success criteria 1.2.4 Captions (Live) and success criteria 1.2.5 Audio Descriptions (Pre-recorded) by the dates indicated in the Regulation.
  • “WCAG 2.0” is an internationally accepted standard for web accessibility developed by an international team of experts.

AODA compliance date : January 1, 2014 (new websites) ; January 1, 2021 (all websites)

Our Actions

We will implement the measures necessary to ensure WCAG 2.0, Level AA, compliance. To meet these requirements, we will hire an outside firm to perform audits and accessibility testing in different sections of the website. Then, to the degree possible, our IT teams will be able to apply the recommendations and do the work necessary to achieve compliance with the requirements before January 1, 2021.

C. Employment Standards

1. Recruitment – General, 2. Recruitment, Assessment or Selection Process, 3. Notice to Successful Applicants

Goal
  • Inform our employees and members of the public of the availability of accommodation for applicants with disabilities who are participating in the Company’s recruitment process.
  • Notify applicants for employment who are individually selected to participate in an assessment or selection process that they may, upon request, have access to accommodations with respect to the materials or processes to be used.
  • Consult with selected applicants who request an accommodation and arrange to provide a suitable accommodation in a manner that takes into account their accessibility needs due to disability.
  • When making offers of employment, inform all successful applicants of the Policy and such other policies that the Company may, from time to time, adopt in order to accommodate employees with disabilities

AODA compliance date : January 1, 2016

Our Actions

We are, directly in our job advertisements, informing our employees and the general public of the availability of accommodation for applicants with disabilities who are participating in the Company’s recruitment process.

We are notifying applicants for employment who are individually selected to participate in an assessment or selection process that they may, upon request, have access to accommodations with respect to the materials or processes to be used. We will consult with successful applicants who request an accommodation in order to provide a suitable accommodation in a manner that takes their accessibility needs due to disability into account.

When making an offer of employment, we give all successful applicants a copy of the Employee Handbook. This handbook contains all the important information about the Company’s policies and procedures, including the policies adopted to support employees with disabilities. These policies are, moreover, updated as required to ensure accessibility of the recruitment process.

4. Informing Employees of Supports

Goal
  • Inform our employees about :
    – the Policy, and such other policies that the Company may, from time to time, adopt in order to support employees with disabilities and
    – the Company’s policies on the provision of job accommodations that take into account the accessibility needs of employees due to disability.
  • Provide this information to new employees as soon as is practicable following the commencement of employment.
  • Provide training on an ongoing basis to reflect changes made to the Company’s policies.

AODA compliance date : January 1, 2016

Our Actions

We make all our employees aware of our Accessibility Standards Policy and such other policies that the Company may, from time to time, adopt in order to support employees with disabilities, as well as the document entitled “Informing Employees of Supports.” This information includes the provision of job accommodations that take into account the accessibility needs of employees due to disability. This information is provided to new employees as soon as is practicable following the commencement of employment. Training will be provided on an ongoing basis to reflect any changes made to the Company’s policies.

5. Accessible Formats and Communication Supports for Employees

Goal

Upon the request of an employee with a disability, consult with the employee to arrange for the provision of accessible formats and communication supports for :
– Information needed to perform the job duties and
– Information generally available to other employees.

AODA compliance date : January 1, 2016

Our Actions

We will, upon request, provide employees with accessible formats and communication supports to enable them to do their work. In determining the relevance of an accessible format or communication support, we will consult with the employee making the request.

6. Workplace Emergency Response Information

Goal
  • Provide individualized workplace emergency response information to employees who have a disability :
    – If we are aware of the need for accommodation due to the disability
    – If the disability is such that the individualized information is necessary and
    – As soon as is practicable, once we become aware of the need for accommodation due to the employee’s disability.
  • If an employee requires assistance and with the employee’s consent, provide the workplace emergency response information to the person designated by the Company to provide assistance to the employee.
  • Review the individualized workplace emergency response information when:
    – The employee moves to a different location within the Company
    – The employee’s overall accommodations needs or plans are reviewed and
    – The Company reviews its general emergency response policies

AODA compliance date : January 1, 2012

Our Actions

Upon the request of an employee with a disability, we will provide individualized workplace emergency response information in an accessible format, if the disability is such that the individualized information is necessary. In situations where an employee with a disability needs help, we will obtain the employee’s consent before sending the individualized information to the person designated to provide assistance, we will update the information if the employee moves to a different location within the Company.

7. Documented Individual Accommodation Plans

Goal
  • Adopt a written process for the development of documented individual accommodation plans for employees with disabilities that meets the requirements of the Regulation.

AODA compliance date : January 1, 2016

Our Actions

We have put in place a written process governing the development and implementation of individual accommodation plans for employees with disabilities who request such a process. It is administered by Human Resources. The goal of the procedure is to enable employees with disabilities to preserve their dignity and independence while carrying out their daily work-related tasks. It includes :

  • The manner in which the employee is able to participate in developing the plan
  • The means used to evaluate the employee individually
  • The manner in which the Company may, at its own expense, ask a medical or other type of expert to carry out an evaluation in order to determine the degree to which the plan can be implemented
  • Employees’ ability to request a representative’s participation in developing the plan
  • The measures the Company has taken to preserve the confidential nature of personal information concerning employees
  • The frequency of plan reviews and updates
  • The manner in which employees would be made aware of the reasons for the Company’s refusal to establish an individual accommodation plan
  • The means used to provide the plan in an accessible format.

8. Return-to-Work Process

Goal
  • Develop and maintain a documented return-to-work process for our employees who have been absent from work due to a disability and who require disability-related accommodations in order to return to work.
  • In the return-to-work process, outline the steps that the Company will take to facilitate the return to work.
  • Include documented individual accommodation plans as part of the return-to-work process.

AODA compliance date : January 1, 2016

Our Actions

We have developed and implemented a return-to-work ( RTW ) process for our employees who have been absent from work due to a disability, to facilitate their reintegration into the workplace. This documented process includes the establishment of individual RTW plans, which may include accommodation ( among other things ) for employees with certain disability-related functional limitations. Rigorous monitoring will be carried out to determine whether the RTW plan should be reviewed based on progress made.

9. Performance Management, Career Development and Advancement, and Redeployment

Goal
  • Take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans, when :
    – Conducting our performance management reviews
    – Providing career development and advancement to our employees and
    – Redeploying employees
  • “Performance management” means a process for assessing and improving employee performance, productivity and effectiveness.
  • “Career development and advancement” includes the assignment of an employee from one position to another within an organization involving an increase in pay or greater responsibility or elevation to a higher level within the organization (or a combination of the above).
  • “Redeployment” means the reassignment of an employee to another department or position within the organization when a particular department or position no longer exists.

AODA compliance date : January 1, 2016

Our Actions

The accessibility needs of employees with a disability are taken into consideration during the performance appraisal process and in connection with career development opportunities. If any employees require and request accommodation in connection with their appraisal, we will ensure that the process used by their manager is responsive to their needs. If an individual accommodation plan has been used in the past, it will continue to apply, or it will be re-evaluated based on the employee’s new functions.

D. Design of Public Spaces

Goal

  • When constructing new spaces on our premises for use by the public, or when redeveloping existing ones, meet the design and accessibility requirements set out in the Regulation.
  • Examples of public spaces include outdoor walkways, parking facilities, service counters and waiting areas.

AODA compliance date : January 1, 2017

Our Actions

We will review the planning of future construction or redevelopment projects to ensure that we meet the design and accessibility requirements set out in the Regulation by the AODA Compliance Date.

Definitions

For the purposes of this Accessibility Plan, the following terms have the meanings indicated.

“Disability” means :

a) Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical coordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device

b) A condition of mental impairment or a developmental disability

c) A learning disability or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language

d) A mental disorder or

e) An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997 ( Ontario ).

Contact us

To find out more about our Accessibility Plan or our Accessibility Standards Policy, please feel free to contact us :

Email : [email protected]